PrimusLabs.com Version Harvest Crew Audit Guidelines

Transcription

1 PrimusLabs.com Version Harvest Crew Audit Guidelines Attention Auditee: Please see for the latest development in GAP Metrics. July 2007 Revision 1 Used in conjunction with v07.04 harvest crew audit PrimusLabs.com 2810 Industrial Parkway Santa Maria, CA Tel Fax V07.04 Rev 1 Page 1 of 25 July 07

2 Index General information Audit Template Definitions, Audit Structures and Scoring Systems 3 Automatic Failure 4 Field Audit Agenda 5 Visual versus Verbal Confirmation 6 Tools and Supplies 7 Glossary 7 V07.04 Rev 1 Page 2 of 25 July 07

3 This document is for guidance purposes only and in no way replaces any regulatory legislation or other legal guidance documentation. PrimusLabs.com accepts no liability for the contents of this document, nor how an individual chooses to apply this document. This document is owned by PrimusLabs.com and as such must be not be copied in whole or in part for any other use. Under no circumstances can this document be copied by or to any person without PrimusLabs.com expressed permission. Website links shown in this document are there to aid understanding and provide assistance. These links are not a sign of endorsement by PrimusLabs.com. Furthermore PrimusLabs.com accepts no liability for the content of these links. If any of the links do not work, please webmaster@primuslabs.com, so that we may update our information. Please be aware that there is additional information on the PrimusLabs.com website including the actual audit templates, web based audit entry system and other useful documents on: This document is designed to be used by all interested parties especially: 1 st Party Auditors, e.g. used by a QA Manager to audit his/her own operation. 2 nd Party Auditors, e.g. a QA Manager who is auditing his/her supplier(s). 3 rd Party Auditors, PrimusLabs.com employed auditors, PrimusLabs.com subcontracted auditors and any affiliated auditors who are using the PrimusLabs.com templates. Useful websites that help further investigate food safety requirements include: Audit Template Definitions, Audit Structures and Scoring Systems You will note that some questions and/or audit guidelines have an asterisk* placed within the text. The asterisk instructs that where laws, commodity specific guidelines and/or best practice recommendations exist and are derived from a reputable source, then these practices and parameters should be used. Audit users should allow a degree of risk association if laws, guidelines, best practices, etc., have not been documented. V07.04 Rev 1 Page 3 of 25 July 07

4 The audit format is updated as needed. Each question is weighted differently depending on the severity. Some questions are asked for survey purposes only meaning that they are not weighted and do not carry a point value however, it is important to note that for future revisions such questions could be converted into questions holding point value. There are three available answers in the PrimusLabs.com field audits: Yes, No, and N/A. Point System Possible Question Points Yes No N/A 20 Point Question points 0 15 Point Question points 0 10 Point Question points 0 7 Point Question 7-7 points 0 5 Point Question 5-5 points 0 3 Point Question 3-3 points 0 2Point Question 2-2 points 0 0Point Question 0 0 points 0 Full compliance Noncompliance Compliance Categories To meet the question and/or compliance criteria in full. The question or compliance criteria has not been fully met (100% compliance). Automatic Failure There are certain questions located in various sections of the audit that are automatic failure questions. If the desired response is not met to any one of these specific questions, the audit will result in score of 0%. However, the audit report will include a breakdown of the scores for each section (summary chart). 2.8 Are there operational toilet facilities provided? If this question is answered No, the audit will result in an automatic failure. If No, go to Is there evidence of human fecal contamination in the growing area? If this Yes, an automatic failure of the audit will occur. V07.04 Rev 1 Page 4 of 25 July 07

5 2.10 Are operational hand washing facilities provided? If No, go to 2.11, If this question is answered No, an automatic failure of the audit will occur If observed, are all commodities that come in contact with blood destroyed? 3.1 Is the crop free of any evidence of systematic animal fecal (e.g. flocking geese, escaped cattle) contamination? If this question is answered NO, this question results in an automatic failure. 3.3b Is packing material free from evidence of pest activity, foreign materials and other signs of hazardous materials? If this question is answered No, an automatic failure of the audit will occur. 3.3c Is packed product free from evidence of pest activity, foreign materials, hazardous materials and any adulteration issues? If this question is answered No, an automatic failure of the audit will occur. Once an audit has been started it cannot be converted into an educational, pre-assessment or consultancy style service. This includes when an automatic failure question as been scored down as noted in the above paragraph. Vice versa, an educational, pre-assessment audit or consultancy service cannot be converted into a standard audit, once the service has begun. Field Audit Agenda A harvest crew audit can vary, depending on the complexity of the operation, equipment involved, crops, season of harvest, picking schedules, weather, etc. In many cases the audit will be an unscheduled situation. However, if it is scheduled and completed in combination with a ranch audit, the normal pattern of events is as follows: Opening Meeting. Confirm the appointment details, introduce the auditor(s) and auditee contacts, and confirm scope. Tour of harvest sites under review (e.g., ranch, farm, vineyard, orchard, grove) File Requirements (paperwork section) Food Security Section. The auditor will have made notes about physical security aspects when carrying out the tour of the operation. These questions are scored. V07.04 Rev 1 Page 5 of 25 July 07

6 Auditor "Quiet" Time. Time required for the auditor to collate notes before delivering the closing meeting. Closing Meeting. Discuss findings with the auditee team. Auditors are not able to provide either a final score or pass/fail commentary at the end of the audit due to the number of questions that are asked in the template. Auditors however do expedite audit reports very quickly and auditees should contact PrimusLabs.com if reports have not been received electronically two weeks after the audit has occurred (at the latest). Once the audit has concluded, the audit is considered to be closed therefore the auditor shall not accept any outstanding documentation. Visual versus Verbal Confirmation Visual confirmation is the default method of auditing, whether during the harvest inspection or the paperwork section. Scores and comments are assumed to have been visually confirmed unless otherwise stated. Verbal confirmations should be the exception to the rule and if auditing properly, these should be rarely used. If a verbal confirmation is accepted, then the auditor should write this in the comments on the question. Auditors should score NA if a discipline such as employee hand washing is not observed at the time of the audit. Tools and Supplies Correct Audit template Audit Guidelines Manual Maps Paper Pens Flashlight Digital Camera (recommended) Global Positioning Satellite (GPS device) Appropriate clothing for conditions Glossary Aerosolized The dispersion or discharge of a substance under pressure that generates a suspension of fine particles in air or other gas. Colony forming units (CFU) Viable micro-organisms (bacteria, yeasts & mold) capable of growth under prescribed conditions (medium, atmosphere, time and temperature) develop into visible colonies (colony forming units) which are counted. Coliforms Gram-negative, non-spore forming, rod-shaped bacteria that ferment lactose to gas. They are frequently used as indicators of process control, but exist broadly in nature. Cross contamination The transfer of microorganisms, such as bacteria and viruses, from one place to another. E. coli Escherichia coli is a common bacteria that lives in the lower intestines of animals (including humans) and is generally not harmful. It is frequently used as an indicator of fecal contamination, but can be found in nature from non-fecal sources. Fecal coliforms Coliform bacteria that grow at elevated temperatures and may or may not be of fecal origin. Useful to monitor effectiveness of composting processes. Also called thermotolerant coliforms. V07.04 Rev 1 Page 6 of 25 July 07

7 Food safety assessment A systematic procedure that identifies hazards and risks from chemical, microbial and physical sources that may be harmful from a food safety perspective. Food safety professional Person entrusted with management level responsibility for conducting food safety assessments before food reaches consumers; requires formal training in scientific principles and a solid understanding of the principles of food safety as applied to agricultural production. Indicator microorganisms An organism used to indicate the potential presence of other (usually pathogenic) organisms. Indicator organisms are usually associated with the other organisms, but are usually more easily sampled and measured. Most probable number (MPN) Estimated values that are statistically derived. A method for enumeration of microbes in a sample when present in small numbers. Oxidation reduction potential (ORP) The ability of water to oxidize or reduce. Measured in millivolts (mv) with an electrode and an electronic meter it gives an indication of ability of oxidizing agents in the water to control contaminants. Parts per million (ppm) A way of expressing very dilute concentrations of substances, usually in water or soil. Parts per million means out of a million just as per cent (%) means out of a hundred. Pathogen A disease causing agent such as a virus, parasite, or bacteria. Risk mitigation actions to reduce the severity/impact of a risk Ultraviolet index (UV index) A measure of the solar ultraviolet intensity at the Earth's surface; indicates the day's exposure to ultraviolet rays. The UV index is measured around noon for a onehour period and rated on a scale of Acronyms and Abbreviations CFU: Colony forming units DL: Detection Limit GAPS: Good agricultural practices INS MPN: Most probable number ORP: Oxidation reduction potential PPM: Parts per million RTE: Ready-to-eat UV: Ultraviolet WHO: World Health Organization V07.04 Rev 1 Page 7 of 25 July 07

8 # Question Guideline Auditor Notes 1 Inspection 1.1 Have self-audits been completed for each harvest crew? Frequent self-audits should be done to identify problems and/or A No response must be justified in comments section. Frequent situations which need improvement. More frequent inspections may inspections should be done to identify problems and/or situations be necessary depending on the type of harvesting activity associated risk pressures. Surveys are designed to identify problems and/or situations which need improvement in advance (maintenance of documentation etc.). Records should show where corrective actions have been made. which need improvement. More frequent inspections may be necessary depending on the type of harvesting activity associated risk pressures. Surveys are designed to identify problems and/or situations which need improvement in advance (maintenance of documentation etc.). Records should show where corrective actions have been made. Visual confirmation (documentation) required. 5 Points No N/A. 1.2 Was a pre-harvest inspection performed on the block being harvested and was the block cleared for harvest? If No, go to 1.3. A pre-harvest block inspection should have been performed and if If No, go to 1.3. A No response must be justified in comments harvesting is occurring, it should show if there are any harvesting section. A pre-harvest block inspection should have been restrictions etc. The harvest crew might not have a copy of the actual performed and if harvesting is occurring, it should show if there are inspection, but they should have a document indicating which any harvesting restrictions etc. The harvest crew might not have a blocks have been inspected and cleared for harvest. * copy of the actual inspection, but they should have a document indicating which blocks have been inspected and cleared for harvest. Visual confirmation (documentation) required.* 5 Points No N/A. 1.2a Where pre-harvest inspections have discovered issues, have buffer zones been clearly identified and at the time of the audit, are these buffer zones being respected? Where pre-inspections have discovered issues e.g. flooding, animal intrusion issues, have the buffer zones been implemented e.g. 30ft (9.1m) from flooded areas, 5ft (1.5m) from evidence of pest activity - use larger buffer zones if national and local laws are more stringent. * Where pre-inspections have discovered issues e.g. flooding, animal intrusion issues, have the buffer zones been implemented e.g. 30ft (9.1m) from flooded areas, 5ft (1.5m) from evidence of pest activity - use larger buffer zones if national and local laws are more stringent. Visual confirmation ( may include documentation if an issue has occurred) required. * 15 Points 1.3 Are there records of daily pre-operation inspections that check key aspects of equipment hygiene, personal hygiene, etc.? Recorded pre-inspections should be designed to cover the key basic issues attributed to the type of harvesting and particular crop being harvested. Aspects to be considered would include equipment hygiene, tool hygiene, and personnel hygiene. Use of ATP is an optional recommendation, but where used, should be recorded properly along with any required corrective actions. A No response must be justified in comments section. Recorded pre-inspections should be designed to cover the key basic issues attributed to the type of harvesting and particular crop being harvested. Aspects to be considered would include equipment hygiene, tool hygiene and personnel hygiene. Use of ATP is an optional recommendation, but where used, should be recorded properly along with any required corrective actions. Visual confirmation (documentation) required. 5 Points No N/A. 1.4 Is there a documented and implemented policy that when commodities are dropped on the ground they are discarded? (Non-applicable for commodities such as tubers, root crops, etc. ) There should be a documented policy that if products are dropped on ground the products are discarded. Staff should trained regarding this policy and records of training maintained. Nonapplicable for tubers and root crops. A No response must be justified in comments section. There should be a documented policy that if products are dropped on ground the products are discarded. Staff should trained regarding this policy and records of training maintained. Non-applicable for tubers and root crops. Visual confirmation (documentation) required. 5 Points No N/A. V07.04 Rev 1 Page 8 of 25 July 07

9 1.5 Is there a food safety hygiene training program covering new and existing employees and are records of these training events? There should be a formal training program to inform employees of the current policies and procedures and requirements of the company regarding hygiene. Frequency should be at the start of the season and then some topics covered at least quarterly, but ideally monthly. Training material covering the content of the company policies/procedures (which includes those items asked in this audit) and requirements regarding hygiene should be available. A No response must be justified in comments section. There should be a formal training program to inform employees of the current policies and requirements of the company regarding hygiene. Frequency should be at the start of the season and then at some topics covered at least quarterly, but ideally monthly. Training material covering the content of the company policies and requirements regarding hygiene should be available. Visual confirmation (documentation) required. 15 Points No N/A. 1.6 Is there a documented and implemented policy stating what happens when harvesters find evidence of animal intrusion e.g. fecal material? 2 Employee Activities & Sanitary Facilities 2.1 Are there any employees observed with improperly covered open wounds? 2.2 Are any employees eating and drinking (other than water) in active harvest areas, areas yet to be harvested, near harvested product or storage areas? There should be a documented and implemented policy stating what happens if harvesting staff find evidence of animal intrusion e.g. fecal material. The policy should cover recorded training of staff regarding this policy, potential corrective actions e.g. product disposal, buffer zones, equipment cleaning and recording of the correctives actions. There should be no employees in harvesting with exposed boils, sores, infected wounds, or any other source of abnormal contamination. All bandages must be covered with a Non-porous covering such as latex or plastic gloves. A No response must be justified in comments section. There should be a documented and implemented policy stating what happens if harvesting staff find evidence of animal intrusion e.g. fecal material. The policy should cover recorded training of staff regarding this policy, potential corrective actions e.g. product disposal, buffer zones, equipment cleaning and recording of the correctives actions. Visual confirmation (documentation) required. 5 Points No N/A. A Yes response must be justified in comments section. There should be No employees in harvesting with exposed boils, sores, infected wounds, or any other source of abnormal contamination. All bandages must be covered with a non-porous covering such as latex or plastic gloves. Visual confirmation required. 5 Points No N/A. Eating and drinking (other than water), including gum chewing must A Yes response must be justified in comments section. Eating and be restricted to areas away from production to prevent contamination drinking (other than water), including gum chewing must be of product, packaging, equipment, and the growing. restricted to areas away from production to prevent contamination of product, packaging, equipment, and the growing area. Visual confirmation required.5 Points No N/A. 2.3 Are any employees using tobacco products in active harvest areas, areas yet to be harvested, near harvested product or storage areas? 2.4 Is it evident the clothing harvesters are wearing is not posing a cross contamination risks? 2.5 Is it evident that employees are free of exposed jewelry (that may pose a foreign contamination issue) except for a single plain ring? Smoking or chewing tobacco must be restricted to areas away from production to prevent contamination of product, packaging, equipment, and the growing area. There should be no evidence of spitting. Cigarette butts should be disposed of appropriately. Harvesters clothing should not be a cross contamination issues in terms of cleanliness. There should be no employees wearing loose objects above the waist (e.g., jewelry) except for a single plain ring. A Yes response must be justified in comments section. Smoking or chewing tobacco must be restricted to areas away from production to prevent contamination of product, packaging, equipment, and the growing area. There should be no evidence of spitting. Cigarette butts should be disposed of appropriately. Visual confirmation required. 5 Points No N/A. A No response must be justified in comments section. Harvesters clothing should not be a cross contamination issues in terms of cleanliness. Visual confirmation (documentation) required. 5 Points No N/A. A No response must be justified in comments section. There should be no employees wearing loose objects above the waist (e.g. jewelry, etc.).visual confirmation required. 5 Points No N/A. V07.04 Rev 1 Page 9 of 25 July 07

10 2.6 Where gloves are required by the auditee, are they appropriate for the type of harvesting ( i.e., not using cotton gloves for harvesting a product such as lettuce) and are they in good working order? If the auditee requires the use of gloves, then the gloves need to be fit for the purpose intended. For example, cotton gloves trap moisture and get dirty easily, therefore are not ideal for an activity such as lettuce harvesting. If the auditee requires the use of gloves, then gloves need to be fit for the purpose intended. For example, cotton gloves trap moisture and get dirty easily, therefore are not ideal for example lettuce harvesting. Visual confirmation required. 5 Points No N/A. 2.6a Where gloves are used, are they latex-free? Information gathering question. Some people are allergic to latex proteins. Using alternatives to latex gloves (especially powdered latex gloves) should be considered. 2.7 If any protective clothing is required by the auditee (e.g., gloves, aprons, sleeves) are they removed prior to using restrooms, going on breaks, etc? 2.7a Are secondary hand sanitation stations (e.g., hand dip, gel or spray stations) adequate in number and location? Are the stations maintained properly? NOTE: Secondary hand sanitation does not replace hand washing requirements (lack surfactant qualities). 2.8 Are there operational toilet facilities provided? If this question is answered No, the audit will result in an automatic failure. If No, go to 2.9 Information gathering question. Some people are allergic to latex proteins. Using alternatives to latex gloves (especially powdered latex gloves) should be considered. Visual confirmation required. 0 Points If outer garments (e.g., gloves, aprons, sleeves) are used, these If should be removed prior to using the restrooms, going on break, etc. outer garments (e.g., gloves, aprons, sleeves) are used, these The use of outer garments is mandated if "in-field processing" is should be removed prior to using the restrooms, going on break, performed. See question 3.9c for further details. etc. The use of outer garments is mandated if in field product "processing" is used, see question 3.9c. Visual confirmation required. 5 Points Secondary hand sanitation stations (non-perfumed) should be located near hand washing and other easily accessible areas. Secondary hand sanitizers are optional for crops with an inedible skin or a commodity that requires cooking prior to eating. Hand gel / spray stations should be well stocked. Hand dips where used should be tested regularly to ensure they are at the required strength - checks should be recorded. Secondary hand sanitizers lack surfactant qualities, therefore does not replace hand washing requirements. The term operational means that the toilets have water, if they are flushing toilet they flush etc. Toilet facilities should be adequately ventilated, appropriately screened, have self-closing doors that can be closed. Privies (unplumbed outhouses) may be allowed only if they are in suitable condition meeting prevailing national/ local standards and guidelines. Secondary hand sanitation stations (non-perfumed) should be located near hand washing and other easily accessible areas. Secondary hand sanitizers are optional for crops with an inedible skin or a commodity that requires cooking prior to eating. Hand gel / spray stations should be well stocked. Hand dips where used should be tested regularly to ensure they are at the required strength - checks should be recorded. Secondary hand sanitizers lack surfactant qualities, therefore does not replace hand washing requirements. Visual confirmation required. 5 Points If No, go to 2.9. A No response must be justified in comments section. The term operational means that the toilets have water, if they are flushing toilet they flush etc. Toilet facilities should be adequately ventilated, appropriately screened, have self-closing doors that can be closed. Privies (unplumbed outhouses) may be allowed only if they are in suitable condition meeting prevailing national/ local standards and guidelines pdf If this question is answered No, the audit will result in an automatic failure.visual confirmation required. 20 Points No N/A. 2.8a Are toilet facilities located in a suitable area and within ¼ mile or 5 minutes walking distance of all employees? Placement of toilet facilities should be in a suitable location to prevent contamination to product, packaging, equipment, and Placement of toilet facilities should be in a suitable location to growing areas. Toilet facility placement should be within 1/4 mile or prevent contamination to product, packaging, equipment, and 5 minutes walking distance of where harvesting crews are located or growing areas. Toilet facility placement should be within 1/4 mile or if more stringent, as per prevailing national/ local guidelines. 5 minutes walking distance of where harvesting crews are located or if more stringent, as per prevailing national/ local guidelines. 10 Points V07.04 Rev 1 Page 10 of 25 July 07

11 2.8b 2.8c 2.8d 2.8e Are toilet facilities in a suitable location to prevent contamination to product, packaging, equipment, and growing areas? Are separate toilet facilities provided for men and women in groups larger than 5 employees? Is a minimum of one toilet facility provided for each group of 20 employees? Do toilet facilities have visuals or signs, written in the appropriate languages, reminding employees to wash their hands before returning to work? Placement of toilet facilities should be in a suitable location to The prevent contamination to product, packaging, equipment, and placement of toilet facilities should be in a suitable location to growing areas. Consideration should be given when portable units prevent contamination to the growing area. Toilets should not be are used that they are not parked (if on trailers) too close to the edge positioned or parked (if mobile) too close to the growing area. Visual of the crop. confirmation required. 15 Points There should be separate toilet facilities provided for men and women in groups larger than 5 employees or if more stringent, as per prevailing national/ local guidelines. At least one toilet per 20 employees should be provided or if more stringent, as per prevailing national/ local guidelines. Toilet facilities should have visuals or signs written in the appropriate languages, reminding employees to wash their hands before returning to work. The visuals or signs should be permanent and placed in key areas where employees can easily see them. There should be separate toilet facilities provided for men and women in groups larger than 5 employees or if more stringent, as per prevailing national/ local guidelines. Visual confirmation required. 5 Points At least one toilet per 20 employees should be provided or if more stringent, as per prevailing national/ local guidelines. Visual confirmation required. 10 Points Toilet facilities should have visuals or signs written in the appropriate languages, reminding employees to wash their hands before returning to work. The visuals or signs should be permanent and placed in key areas where employees can easily see them. Visual confirmation required. 5 points 2.8f Are toilets supplied with toilet paper and is the toilet paper maintained properly (e.g. toilet paper rolls not stored on the floor or in the urinals)? 2.8g Toilet paper should be provided in a suitable holder in each toilet facility. Toilet paper should be maintained properly (e.g. toilet paper rolls not stored on the floor or in the urinals). Are the toilets maintained in a clean condition? Toilet facilities shall be operational and maintained in clean and sanitary condition Soiled tissue should not be placed in trash cans, urinals, or on the floor. Effective odor control should be practiced at all toilet facilities. Toilet paper should be provided in a suitable holder in each toilet facility. Toilet paper should be maintained properly (e.g. toilet paper rolls not stored on the floor or in the urinals). Visual confirmation required. 5 Points Toilet facilities shall be operational and maintained in clean and sanitary condition. Soiled tissue should not be placed in trash cans, urinals, or on the floor. Effective odor control should be practiced at all toilet facilities. Visual confirmation required. 10 Points 2.8h Are toilets constructed of materials that are easy to clean? Toilet facilities should be constructed of non porous materials that are easy to clean and sanitize. Toilet facilities should be constructed of non porous materials that are easy to clean and sanitize.visual confirmation required. 2 Points 2.8i Are the toilet's construction materials of a light color allowing easy evaluation of cleaning performance? Toilet's should be constructed of materials light in color allowing easy evaluation of cleaning performance. Toilet's should be constructed of materials light in color allowing easy evaluation of cleaning performance. Visual confirmation required. 2 Points V07.04 Rev 1 Page 11 of 25 July 07

12 2.8j Is there a documented and implemented policy that if portable toilets are used, waste is disposed of properly and the units are cleaned in an appropriate location? For portable toilets there should be a documented and implemented For procedure available covering emptying and cleaning. The concern is portable toilets there should be a documented and implemented that waste might be disposed of inappropriately causing procedure available covering emptying and cleaning. The concern contamination in or near the growing area, equipment and storage is that waste might be disposed of inappropriately causing areas. If there is an on the farm designated "wash out" and waste contamination in or near the growing area, equipment and storage disposal site, then the area must be in a suitable condition meeting areas. If there is an on the farm designated "wash out" and waste prevailing national/ local standards and guidelines which pose no disposal site, then the area must be in a suitable condition meeting threat for contamination. prevailing national/ local standards and guidelines which pose no threat for contamination. Visual confirmation (documentation) required. 5 Points 2.8k Are there toilet cleaning records and for portable toilets, are there servicing records? There should be cleaning records available for toilets. Frequency depends on use, but usually the baseline is daily for regular harvest crews. Portable toilets should be emptied and serviced regularly to prevent overflow. Servicing records (either contracted or in-house) should be available for review. There should be cleaning records available for toilets. Frequency depends on use, but usually the baseline is daily for regular harvest crews. Portable toilets should be emptied and serviced regularly to prevent overflow. Servicing records (either contracted or in-house) should be available for review.visual confirmation (documentation) required. 2 Points 2.8l If used, are catch basins of the toilets designed and maintained to prevent contamination (e.g. free from leaks and cracks)? Catch basins from toilets must be designed and maintained properly to prevent contamination onto field, product, packaging, and equipment. Catch basins should be free of leaks, cracks and constructed of durable materials that will Not degrade or decompose such as wood. Catch basins from toilets must be designed and maintained properly to prevent contamination onto field, product, packaging, and equipment. Catch basins should be free of leaks, cracks and constructed of durable materials that will not degrade or decompose such as wood.visual confirmation required. 5 Points 2.8m Are the toilet catch basins emptied properly? If self contained toilets are used, the toilet basins should be emptied/ pumped in a manner to avoid contamination to product, packaging, equipment, and growing areas. Equipment used in emptying/pumping must be in good working order. If self contained toilets are used, the toilet basins should be emptied/ pumped in a manner to avoid contamination to product, packaging, equipment, and growing areas. Equipment used in emptying/pumping must be in good working order. Visual confirmation required. 5 Points 2.9 Is there evidence of human fecal contamination in the growing area? If this Yes, an automatic failure of the audit will occur. There should be no evidence of human fecal contamination in the growing area, area being harvested, packaging area, equipment area, or in any other area that would cause a contamination issue. A Yes response must be justified in comments section. There should be no evidence of human fecal contamination in the growing area, area being harvested, packaging area, equipment area, or in any other area that would cause a contamination issue. Visual confirmation required. 20 Points. No N/A 2.1 Are operational hand washing facilities provided? If No, go to 2.11, If this question is answered No, an automatic failure of the audit will occur. Operational "Hand washing facility" means a facility providing either a basin, container, or outlet with an adequate supply of potable water. If No, go to 2.11 and mark the following questions N/A. A No response must be justified in comments section. Operational "Hand washing facility" means a facility providing either a basin, container, or outlet with an adequate supply of potable water. If this question is answered No, an automatic failure of the audit will occur. Visual confirmation required. 20 Points. No N/A V07.04 Rev 1 Page 12 of 25 July 07

13 2.10a Are the hand washing facilities placed within ¼ mile or 5 minutes walking distance of all employees? Toilet and hand washing facilities should be accessibly located an in Toilet close proximity to each other. Hand washing facilities should be and hand washing facilities should be accessibly located an in provided and placed within 1/4 mile or 5 minutes walking distance of close proximity to each other. Hand washing facilities should be the harvest crew or if more stringent, as per prevailing national/ local provided and placed within 1/4 mile or 5 minutes walking distance guidelines. of the harvest crew or if more stringent, as per prevailing national/ local guidelines.visual confirmation required. 15 Points. 2.10b 2.10c 2.10d 2.10e Are hand wash stations clearly visible (e.g. situated outside the toilet facility) and easily accessible to workers? In the event of running out of toilet materials (e.g., water, soap, toilet tissue, hand paper towels) are there extra supplies readily available so that toilets can be restocked quickly? Is soap made available at all hand washing facilities? If No, go to 2.10f. So employee's hand washing activities can be verified, hand wash stations should be clearly visible (i.e. situated outside the toilet facility) and easily accessible to workers. There should be readily available an extra stock of fresh water, soap, toilet paper and paper towels, etc. in the event that replenishment is needed while harvesting is occurring. All hand washing facilities must be stocked with soap. Liquid/foam/powder with single use pump dispenser method preferred over communal bar type. Is non-perfumed soap available? Soap should be non-perfumed and have emulsifying capabilities to aid in the hand washing procedure. 2.10f Are single-use towels available at all hand washing facilities and trash cans for them? To reduce the spreading of germs, single-use towels available at all hand washing facilities. Trash cans should be supplied for used towels. A No response must be justified in comments section. So employee's hand washing activities can be verified, hand wash stations should be clearly visible (i.e. situated outside the toilet facility) and easily accessible to workers. Visual confirmation required. 2 Points There should be readily available an extra stock of fresh water, soap, toilet paper and paper towels, etc. in the event that replenishment is needed while harvesting is occurring. Visual confirmation required. 5 Points All hand washing facilities must be stocked with soap. Liquid/foam/powder with single use pump dispenser method preferred over communal bar type. Visual confirmation required. 10 Points Soap should be non-perfumed and have emulsifying capabilities to aid in the hand washing procedure. Visual confirmation required. 5 Points To reduce the spreading of germs, single-use towels available at all hand washing facilities. Trash cans should be supplied for used towels.visual confirmation required. 10 Points 2.10g Are the hand wash stations designed and maintained properly (e.g. ability to capture or control rinse water to prevent contamination onto product, packaging, and growing area, free of clogged drains, etc)? Hand wash stations should be free of clogged drains, designed and maintained properly to capture or control rinse water that could cause contamination onto product, packaging, equipment, and growing area. Hand wash stations should be free of clogged drains, designed and maintained properly to capture or control rinse water that could cause contamination onto product, packaging, equipment, and growing area. Visual confirmation required. 5 Points 2.10h Are the employees washing their hands prior to beginning work? Score NA if this discipline is not observed at the time of the audit. To prevent contamination to product, packaging, and equipment, To employees should wash their hands prior to beginning work. Also prevent contamination to product, packaging, and equipment, after sneezing, placing there hands in their pockets and at any other employees should wash their hands prior to beginning work. Also point when cross contamination could occur. It also must be evident after sneezing, placing there hands in their pockets and at any other that employee's fingernails are kept clean and trimmed. point when cross contamination could occur. It also must be evident that employee's fingernails are kept clean and trimmed. Auditors should score NA if this discipline is not observed at the time of the audit. Visual confirmation required. 10 Points V07.04 Rev 1 Page 13 of 25 July 07

14 2.10i Are the employees washing their hands after break periods? Score NA if this discipline is not observed at the time of the audit. 2.10j Are the employees washing their hands after using the toilet facilities? Score NA if this discipline is not observed at the time of the audit. 2.10k Is it evident that corrective action is taken when employees fail to comply with hand washing guidelines? 2.11 Is fresh potable drinking water readily accessible to employees.? If No, go to To prevent contamination to product, packaging, and equipment, To employees should wash their hands after break periods. It also must prevent contamination to product, packaging, and equipment, be evident that employee's fingernails are kept clean and trimmed. If employees should wash their hands after break periods. It also employees hands some into contact with mucous, hands must be must be evident that employee's fingernails are kept clean and washed. trimmed. If employees hands some into contact with mucous, hands must be washed. Auditors should score NA if this discipline is not observed at the time of the audit. Visual confirmation required. 10 Points To prevent contamination to product, packaging, and equipment, employees should wash their hands after using toilet facilities. It also must be evident that employee's fingernails are kept clean and trimmed. It should be evident that corrective action is taken by a supervisor in charge when employees fail to comply with hand washing requirements. To prevent contamination to product, packaging, and equipment, employees should wash their hands after break periods. It also must be evident that employee's fingernails are kept clean and trimmed. If employees hands some into contact with mucous, hands must be washed. Auditors should score NA if this discipline is not observed at the time of the audit. Visual confirmation required. 15 Points It should be evident that corrective action is taken by a supervisor in charge when employees fail to comply with hand washing requirements. Auditors should score NA if there are no issues to warrant corrective action. Visual confirmation required. 5 Points Water should be suitably cool and in sufficient amounts, taking into If No, go to and mark the following question N/A. A No account the air temperature, humidity and the nature of the work response must be justified in comments section.water should be performed, to meet the needs of all employees. Potable water should suitably cool and in sufficient amounts, taking into account the air be provided and placed in locations readily accessible to all temperature, humidity and the nature of the work performed, to employees. Potable meaning drinking water quality e.g. the EPA meet the needs of all employees. Potable water should be provided Drinking Water Standard. and placed in locations readily accessible to all employees. Potable meaning drinking water quality e.g. the EPA Drinking Water Standard. Visual confirmation required. 7 Points No N/A. 2.11a Are the water containers maintained in a clean condition? Water containers should be maintained in a clean condition, free from residues and contamination to ensure employees are not adversely affected by contaminated water from unclean containers. Water containers should be maintained in a clean condition, free from residues and contamination to ensure employees are not adversely affected by contaminated water from unclean containers. Visual confirmation required. 5 Points 2.11b 2.12 Are single use cups provided (unless a drinking fountain is used) made available near the drinking water? Are first-aid kits available and is the inventory maintained properly? Water should be provided so that cross contamination issues are avoided from person to person. Examples include single-use paper cups, drinking fountains, etc. There should be a first-aid kit available that is stocked with inventory (e.g. disposable gloves, bandages) and accessible for employees. All date coded materials are within expiry dates. Water should be provided so that cross contamination issues are avoided from person to person. Examples include single-use paper cups, drinking fountains, etc. Visual confirmation required. 7 Points A No response must be justified in comments section. There should be a first-aid kit available that is stocked with inventory (e.g. disposable gloves, bandages) and accessible for employees. All date coded materials are within expiry dates. Visual confirmation required. 5 Points. No N/A. V07.04 Rev 1 Page 14 of 25 July 07

15 2.13 If observed, are all commodities that come in contact with blood destroyed? If this question is answered No, an automatic failure of the audit will occur. Any commodity that comes into contact with blood must be destroyed. If this occurs during the time of inspection, auditor must witness that product is destroyed. Any commodity that comes into contact with blood must be destroyed. If this occurs during the time of inspection, auditor must witness that product is destroyed and that the event is recorded in an Unusual Occurrence Log or equivalent type of Log. If this question is answered No, an automatic failure of the audit will occur.visual confirmation (which may include documentation if an issue has occurred) required. 20 Points 2.13a 2.14 Is there a documented and implemented policy and procedure in place and available for all commodities that come in contact with blood to be destroyed? Is garbage disposed of properly in the harvested and non harvested areas? There should be a documented policy and procedure that is There communicated to harvest crew workers detailing that if product has should be a documented policy and procedure that is come into contact with blood, all affected product must be destroyed. communicated to harvest crew workers detailing that if product has Special attention should be given to those crops where tools come into contact with blood, all affected product must be /equipment (e.g., knives, scissors) is used. destroyed. Special attention should be given to those crops where tools /equipment (e.g., knives, scissors) is used.visual confirmation (documentation) required. 5 Points Waste and garbage must be removed on a frequent basis to prevent contamination from occurring. Receptacles should be kept covered or closed to prevent contamination and attraction of pests. A No response must be justified in comments section. Waste and garbage must be removed on a frequent basis to prevent contamination from occurring. Receptacles should be kept covered or closed to prevent contamination and attraction of pests. Visual confirmation required. 10 Points. No N/A Are garbage containers provided in the field for the disposal of food and beverage containers, cups, and paper towels? If No, go to a Are garbage containers constructed and maintained (e.g. bags, lids) to protect against pre harvest or post harvest contamination of the crop? Garbage containers should be provided in the field for the disposal of food and beverage containers, cups, and paper towels. Garbage containers should be constructed and maintained in such a manner with liners, bags, lids, etc.) that protects against pre harvest or post harvest contamination of the crop. Receptacles should be kept covered or closed to prevent attraction of pests. Liners are important so trash can be removed easily. If No, go to 2.16 and mark the following questions N/A. A No response must be justified in comments section. Garbage containers should be provided in the field for the disposal of food and beverage containers, cups, and paper towels. Visual confirmation required. 5 Points. No N/A. Garbage containers should be constructed and maintained in such a manner with liners, bags, lids, etc. that protects against pre harvest or post harvest contamination of the crop. Receptacles should be kept covered or closed to prevent attraction of pests. Liners are important so that trash can be removed easily. Visual confirmation required. 5 Points 2.16 Have any potential metal, glass, or plastic contamination issues been controlled? Examples include but are not limited to glass bottles, unprotected lights on equipment, staples on wooden crates, hair pins, using snappable blades instead of one piece blades, broken and brittle plastic issues on re-useable totes. A No response must be justified in comments section. This questioned is designed to allow the auditor to underline potential foreign material contaminants to the auditee that are not covered by other more specific questions within the audit. Visual confirmation required. 5 Points. No N/A. V07.04 Rev 1 Page 15 of 25 July 07

16 3 Harvesting Practices 3.1 Is the crop free of any evidence of systematic animal fecal (e.g. flocking geese, escaped cattle) contamination? If this question is answered NO, this question results in an automatic failure. 3.2 Is there evidence of animal activity in the crop that is a potential food safety risk? Systematic animal fecal contamination refers to find evidence of A No, response must be justified in comments section. Systematic flocks, herds, groups of animals fecal material in an area of the crop. animal fecal contamination refers to find evidence of flocks, herds, In un-harvested areas, a harvest pre-assessment should have groups of animals fecal material in an area of the crop. In unharvested areas, a harvest pre-assessment should have detected detected this issue. In harvested areas, the affected areas and buffers zones should have been left un-harvested. this issue. In harvested areas, the affected areas and buffers zones should have been left un-harvested. If this question is answered Yes, this question results in an automatic failure. Visual confirmation (which may include documentation) required. 20 Points. No N/A Produce that has come into direct contact with fecal material must A Yes response must be justified in comments section. Produce not be harvested and a 5ft (1.5m) radius no harvest zone that has come into direct contact with fecal material must not be implemented unless or until adequate mitigation measures have harvested and a 5ft (1.5m) radius no harvest zone implemented been considered. If evidence of fecal material is found, a food safety unless or until adequate mitigation measures have been assessment must be conducted by qualified personnel. This considered. If evidence of fecal material is found, a food safety question is answered "no" if the grower has already noted this assessment must be conducted by qualified personnel. This issues and performed adequate correct actions. * question is answered "no" if the grower has already noted this issues and performed adequate correct actions. Visual confirmation (which may include documentation) required. * 20 Points. No N/A 3.3 Is the product packed in the final packing unit in the field? If No, go to a 3.3b Is packing material (e.g. cartons, bags, clamshells, sacks, RPCs) intended for carrying product used for that purpose only? This question refers to product packed in the field that is in the final unit for shipping (i.e. clamshell, wrapped products, etc.), that usually bypasses any selection packing lines in a facility i.e. goes to a cooling process as opposed to a packing line. All containers intended for product should not be used for any other purpose than product storage. Is packing material free from evidence of pest activity, foreign Packing material should be free from evidence of pest activity, materials and other signs of hazardous materials? If this foreign materials and other signs of hazardous materials. question is answered No, an automatic failure of the audit will occur. If No, go to 3.4 and mark the following questions N/A. This question refers to product packed in the field that is in the final unit for shipping (i.e. clamshell, wrapped products, etc.), that usually bypasses any selection packing lines in a facility i.e. goes to a cooling process as opposed to a packing line. Visual confirmation required. 0 points. No N/A All containers intended for product should not be used for any other purpose than product storage. Visual confirmation required. 5 points. Packing material should be free from evidence of pest activity, foreign materials and other signs of hazardous materials. If this question is answered No, an automatic failure of the audit will occur. Visual confirmation required. 20 points. 3.3c Is packed product free from evidence of pest activity, foreign materials, hazardous materials and any adulteration issues? If this question is answered No, an automatic failure of the audit will occur. Packed product should be free from evidence of pest activity, foreign materials, hazardous materials and any adulteration issues. Packed product should be free from evidence of pest activity, foreign materials, hazardous materials and any adulteration issues. If this question is answered No, an automatic failure of the audit will occur. Visual confirmation required. 20 points. V07.04 Rev 1 Page 16 of 25 July 07